New Account Opening
Question: I am having a little trouble with what documentation to use when opening an account for an unincorporated association. Could you advise me of what documents I would need to get from them?
Answer: These types of customer accounts are difficult. At a minimum, you should obtain basic CIP information on any individual authorized to access the account. If this changes each year, you should require a new signer to come in for the purpose of identification. If at all possible, you should also ask for some sort of official documentation for the organization. What most banks are asking for is the tax status documentation. That is often the only real documentation that exists for this type of organization. If they have filed with the state to make the association official, the state's documents would be good for identification.
Any charitable organization must file with the IRS to be approved as tax exempt. If the customer/association doesn't know anything about it, they may be operating outside of the law if they are doing anything that brings in income - even a bake sale! The forms should be available on the IRS website. Most charitable organizations file as a 501(c)(3) which is the section number of the charitable exemption law.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 12, 11/04
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